Machinery Directive and Lockout Tagout: How do they complement each other?

• Posted on 16 September 2025
• By Marit Krol
• Posted in lockout tagout, Machinery Directive
• 0

Anyone in Europe who works with machinery must follow the Machinery Directive (2006/42/EC). This law requires that machines are designed and supplied in a safe condition before they can be sold or used. The manufacturer is responsible for building safety into the design, but once the machine is in operation, the employer is responsible for keeping it safe during daily use and maintenance. This is where Lockout-Tagout (LOTO) becomes important.

The Machinery Directive aims to remove risks at the design stage, as far as possible. This includes fixed guards to stop access to dangerous moving parts, emergency stop buttons, and interlocks that make it safer to access machines. The idea is to reduce hazards before the machine is ever switched on. But design alone cannot prevent all risks. During maintenance, cleaning, or repair, machines still contain energy sources such as electricity, hydraulics, compressed air, heat, or stored movement. These must be fully isolated to protect workers. LOTO provides a clear and practical way to do this, with devices and procedures that make energy isolation visible and verifiable.

LOTO achieves this by locking energy-isolating devices in the “off” position, such as main switches, circuit breakers, or valves. A padlock and tag are applied so that no one can restart the machine until the person doing the work has removed the lock. This prevents accidental start-up, release of stored energy, or the risk of someone being trapped inside a dangerous area. By using personal locks, each worker controls their own safety, and it is impossible to re-energise the machine until all locks have been removed. In this way, LOTO directly prevents the most common causes of serious incidents during maintenance: unexpected start-up, movement of parts, and release of energy.

A common misunderstanding is that a CE-marked machine is automatically safe during maintenance. In reality, the CE mark only confirms that the machine met the Directive’s requirements when it was built. It does not remove dangers such as trapped pressure or sudden movement. Many serious accidents happen during servicing because of these risks. This is why LOTO is essential as the daily safeguard to complement the basic safety built into the machine.

For HSE managers, this means both design safety and operational safety must be part of the company’s safety plan. Risk assessments should also cover maintenance work, and clear LOTO procedures, training, and checks are needed to prove that energy isolation is under control. For procurement staff, the CE mark alone is not enough when choosing machinery. They also need to check whether machines can be locked out safely. This means making sure there are main switches, isolation points, and valves that can be locked with LOTO devices. If these are missing, costly modifications may be needed later.

The Machinery Directive and Lockout-Tagout are not separate systems, but two parts of the same safety structure. Design safety reduces risks at the source, and operational safety through LOTO controls risks during the machine’s life cycle. Together, they provide a strong and practical way to keep both compliance and worker safety under control.